C01.0 Externally Sponsored Projects Disclosure Policy

The increasing extent and complexity of scholarship at RIT, especially as it involves student participation, underscores the importance of the university’s general commitment to openness in scholarship.  Of particular concern to the RIT Community are projects that receive funds from external sources.  To the extent that external funding sources are involved, projects need to be governed by a university oversight policy.

External funding sources may have interests that do not coincide with those of the university.  In addition, the interests of individual faculty, who as professionals judge what scholarship ought to be pursued and how best to pursue it, may not always coincide with those of the university or with the interests of students or others.  Therefore, the Externally Sponsored Projects Disclosure Policy (the Policy) requires striking a balance among the sometimes contending interests of the individual scholar, the external funding source, students and other participants, and the university.  Externally sponsored projects must also conform to professional, ethical, financial and legal standards, as well as contractual conditions specified by the university.  Beyond that, no single set of interests can be fully satisfied; at best one can try to further the most important interests while doing minimal harm to the others.  To facilitate this process of optimization, there is need for a clear, written policy for externally funded projects based on the principles listed in Section II. 

The Policy uses the following terms (defined in Section  V):  Agreement, Classified Information, Externally Sponsored Projects, University Subsidiary, Pertinent Details, Proprietary Information, and RIT Community. 

The Policy shall be implemented and administered on the basis of each of the following principles, balanced against one another in a manner best suited to the RIT community:

1. That there be openness in scholarship -- The principle of freedom of access by all interested members of the RIT Community to the underlying data, to the methodologies, and to the final results of scholarship is important; such data, methodologies, and results should be disseminated through normal scholarly means;
2. That students and other participants be informed -- Students and any other participants, whether paid or unpaid, shall be informed of the Pertinent Details of Externally Sponsored Projects with which they are involved; 
3. That there be freedom of choice -- Individual faculty, staff, and students shall have the freedom to pursue external funding and to select the projects with which they are involved, including ones that involve Classified Information; 
4. That there be maximum disclosure -- All Agreements involving Externally Sponsored Projects are to be written, with Pertinent Details made a matter of record for the RIT Community; 
5. That there be minimum intrusion -- Any disclosure or review process of Externally Sponsored Projects shall minimize the burden on normal university processes and procedures; 
6. That scholars be responsible -- Those engaged in scholarship are to abide by the university policies and procedures, which includes the definition of scholarship at RIT. They are also to make clear in any publication or scholarly communication the source(s) of funding that made their work possible; they are to honor the terms of the Agreement(s) the university entered into on their behalf; and they are to ensure that the underlying data, methodologies, and results of their scholarship are not represented as having RIT endorsement; and
7. That there be independent oversight -- A university committee called the Research Compliance Committee (the Committee) which is a standing sub-committee of the university’s Compliance Committee shall ensure compliance with the Policy.  This includes considering issues arising under the Policy and reviewing the Policy as needed.

1. Agreements between external sponsors and the university or a University Subsidiary must obtain approval in accordance with existing RIT policies and procedures.  However, the following situations require prior review and shall result in recommendations from the Committee to the provost for appropriate action:

   1. requests for a limited level of disclosure of Pertinent Details;

   2. projects that create or make use of Classified Information.
      
      No request to keep secret the fact of a project’s existence or of its funding source shall be approved.

2. Pertinent Details of all Externally Sponsored Projects shall be accessible to the RIT community via RIT's sponsored projects online database.  This record shall be managed by the office responsible for managing external grants and contracts. Additional information related to all Agreements shall be kept on file in the responsible university office, accessible to the Committee upon request.
3. Detailed procedures for the oversight process shall be available in a document entitled, “Procedures for Implementing and Administering the Disclosure Policy for Externally Sponsored Projects.”

1. The Committee shall: review, develop, and manage procedures for implementing the Policy; conduct educational outreach to students, faculty, and staff; ensure an independent audit record of the Policy periodically; hear complaints arising under the Policy; and make recommendations related to the Policy.  The Committee shall deliver an annual report to the university's Compliance Committee and the governance groups.  The report shall summarize the degree of compliance with the Policy and any prior review recommenations to the provost.
2. The university’s Compliance Committee was established pursuant to the implementation of C0.0 (Compliance Policy and Code of Ethical Conduct). The Committee shall be a standing sub-committee of the university’s Compliance Committee with its membership to include a representative chosen by and from Faculty Senate, Staff Council, and Student Government.
3. The Committee shall meet as necessary to conduct its business, but a minimum of two times during the academic year. 
4. Nominees or appointees to the Committee shall disclose potential conflicts of interest, such as being a consultant to a company that regularly has Agreements with RIT.  Names of all Committee members shall be made accessible to the RIT Community.  Other records accessible to the RIT Community shall include meeting agendas, minutes, audit reports, and annual reports.  The format for all accessible records shall be determined by the Committee.
5. Complaints and non-compliance issues shall be approached as follows:

   1. Any concerns about the Committee’s operations shall be brought first to the Committee’s attention; second to the university's Compliance Committee; then — if unresolved — to the provost; and finally, in the form of a formal written complaint, to the Faculty Senate, Staff Council, Student Government, and University Council. 

   2. Any concerns the Committee may have about non-compliance with the Policy shall be brought first to the attention of the principal investigator and the principal investigator's department head and dean; second to the university's Compliance Committee; then — if unresolved — to the attention of the provost; and finally, in the form of a written notice of non-compliance, to the Faculty Senate, Staff Council, Student Government, and University Council.

1. Agreement means any contract or grant for any study, services, or research between an external funding source and the university or any University Subsidiary. 
2. Classified Information is any information or material that has been determined by the US Government to require protection against unauthorized disclosure for reasons of national security. 
3. Externally Sponsored Projects are studies, services, and research performed by Agreement with RIT involving non-university funds or resources.  Gifts and resources transferred with charitable intent are not considered Externally Sponsored Projects.
4. University Subsidiary means any organization which is a wholly-owned subsidiary of the university or one in which the university has majority controlling interest.
5. Pertinent Details include all of the following:

   • name of the principal investigator,

   • title of the project, 

   • abstract of the project,

   • name of the sponsor and original source of funds (if different),

   • amount of the project funding, 

   • project’s duration, and

   • existence of any Classified Information.

6. RIT Community refers to persons with email accounts maintained by RIT.

Responsible Office: Board of Trustees

Approval Date:
March 10, 1993 - Original Research Oversight Policy approved by the Board of Trustees

Effective Date:  March 10, 1993

Policy History:
November 14, 1996 - Education Committee of the Board of Trustees approved procedural changes 
January 21, 2002 - Executive Committee of the Board of Trustees approved procedural changes 
January 16, 2007 - Executive Committee of the Board of Trustees adopted Oversight Policy for Externally Sponsored Projects (replaces Research Oversight Policy) 
Edited August 2010
July 10, 2015 – Board of Trustees adopted the Externally Sponsored Projects Disclosure Policy (replaces the Oversight Policy for Externally Sponsored Projects Policy)
January 16, 2023 - Reviewed and reaffirmed